Wien, 11. Mrz 2013 Dear Mr. Commissioner Tonio Borg!

The Austrian beekeepers had to recognize with growing concern the issue of the effects of neonicotinoids on our honeybees, but also on wild bees and other pollinators. Already before the disaster in 2008 in the Upper Rhine Valley unexplicable colony collapse was observed in intensive maize growing areas in addition to other damage to bee colonies. From 2009 to 2012 the beekeepers in Austria took part in the research project Melissa. Through intensive cooperation the damages were scientifically examined and clear connections between the effects of neonicotinoid seed treatments on colony collapse and colony damage were observed. Also from the EU mandated monitoring for 2012 has unambiguously proved in more than 50% of the examined cases that the damages reported by the beekeepers could be traced back to the use of neonicotinoids. Numerous scientific investigations over the last few years have shown unambiguously that the neonicotinoids used mainly in agriculture are able to kill bees. Also very low concentrations of these active substances will damage the coloniey as a whole and influence it in negative way, so that the bees can no longer carry out their duties in the colony. For the beekeepers it was a positive and hopeful sign that you have proposed to suspend the registration for neonicotinoid seed treatments responsible damage to honeybees (and many other pollinators) for 2 years. This is already a compromise compared to our justified demand of a complete ban of the entire group of these active ingredients.

A-1010 Wien, Georg Coch Platz 3/11 a Telefon (+43 1) 512 54 29, Telefax (+43 1) 512 54 29-4, e-mail: oesterr.imkerbund@aon.at Homepage: www.imkerbund.at PSK-Konto 1896.471, BLZ 60000 ATU 39422503 ZVR 682681379

2 Your proposal represents a big chance to reach an European solution for the health of the bees and it is high time for those responsible to agree to your proposal at the next Scofcah meeting on the 14th-15th of March. Now I it has come to my attention that Copa-Cogeca in a recent letter to the EU member states tried to lobby for the introduction of the so-called " leeway-diminishing measures " (Mitigation Measures) and Austria should hold out as an example of a success of these measures. Especially in Austria these measures were cited over and over again to justify the application of these substances and it had been claimed that they had been success. The opposite is the case: As the Italian investigation APENET proves, the use of deflectores which should direct the toxic dust on the ground result in a substantially higher concentration of these poisons in the surface of the soil. A case of massive damage documented in the Austrian monitoring in 2012 suggests that in the end this massive concentration of the toxic dust has caused the poisoning of bees engaged in the water collecting especially after a subsequent rainfall. Looking back in time the 42 colonies of the affected apiary had developed well up to the time of the maize sowing as a result of a good honey flow from rape normally and also had collected honey (bees occupied the brood box in the Dadant size; about that 2 3 half-height honey supers). From the time of the incident it went downhill with the colonies. Queens and drones died, the colony strength decreased and after approx. 14 days the frames were without bees in about 40 colonies. Also in the two surviving colonies the queens had dropped dead. These two hives could only be revived by adding new queens. According to the beekeeper the main damage had appeared with a time delay to the maize sowing. At the time of the strongest deathrate of the bees the maize in the field in the immediat vicinity of the apiary had already developed (fig. 5 b) and it had strongly been raining after longer drying spell. In the course of the survey of the site by an employee of the department for bee research and bee protection bees could be observed in the corn field which apparently tried to soak up humidity with outstretched trunk from the ground. The affected beekeeper had already made the same observation.

From the results of the residue analysis and these observations however, guttation drops as well as contaminated soil moisture have to be considered as possible exposition sources./ (Austrian Monitoring Report Page 15). Investigations conducted in the year 2011 with regard to the drift mitigation measure Sowing only with wind speed smaller than 5 m/s conclude that during this particular year in no region at no time the sowing of maize could have taken place in compliance with this measure. "/The maximum permitted wind speed of 5 m/sec (= 50 tenth meters / sec in the pictures) required by the registration since 2011 for the sowing of insektizide treated maize or pumpkin seed was exceeded during all three project years during most days for three time frames studied (7 o'clock, 12 o'clock, 19 o'clock daylight savings time not taken into consideration) crossed. When applying the registration requirements in effect since 201 for these days, or at these times, no sowing of insektizide treated maize or pumpkin should have taken place. The actual peak wind speeds recorded at the time of the maize sowing were in numerous cases about double and less frequent around fourfold the permitted value of 5 m/sec/ (Melissa Final Report Page 154 157) Even if in 2012 less cases of damage were reported the causes for this were not examined: Weather related? frustration of beekeepers who had suffered repeated damage? the results of the monitoring show for 2012 that the measures enacted by the authorities have been insufficient: there were again clear cases of damage and more than half of these were also unambiguously attributable to neonicotinoids: In all cases with positive residue test results in bees or bee bread the exposition of the bee colonies with the examined active substances was shown unambiguously. Also the damaged bees showed typical poisoning symptoms in the affected apiaries. On account of the temporal coincidence of the bee's damages at the beginning of the maize cultivation in the affected areas and the detected active substances in particular to the active insecticide ingredients Clothianidin and Thiamethoxam used as seed treatment in maize , a causal connection arises with their application in this crop. The frequency of the damage reports in April and May, as well as the substantially higher share of tests with positive residue results compared to the period June till September-, is another unequivocal inducation for this.

As to the decline of the reported cases of damage: Interestingly, in the percentage of the apiaries with positive residue results for the active substances Clothianidin, Thiamethoxam, Imidacloprid and Fipronil (incl. Fipronilsulfon) this decline is not reflected. While from 2009 to 2011 in the project MELISSA the percentage of the apiaries with positive results for the active substances in question continuously declined from 93% to 71% down to 52% , the survey carried out this year shows a *stagnation at 51%.* (Monitoring Projekt Report). The experiences of the Austrian beekeepers show that mitigation measures required by the farmers have brought no essential improvement, and present for the farmers only difficulties and requirements which cannot be complied with in the practice of the everyday work. The damage to bees recently shown in the 2012 monitoring indicate this also objectively. Hence, dear Mr. Commissioner, we ask you to be steadfast with your original proposal in the interest of the honeybees, the wild bees, butterflies and all pollinating insects, to benefit biodiversity in our European landscape. With many thanks for your efforts sincerely

Maximilian Liedlbauer President Austrian Beekeepers Association